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Read need-to-know updates, commentary, and analysis on Tax issues written by leading professionals.

Benefits Litigation Update – Spring 2017

by Epstein Becker & Green on

Welcome to the Spring edition of Benefits Litigation Update, brought to you by The ERISA Industry Committee (ERIC) and the law firm Epstein Becker & Green. As a new Congress, and a new executive branch, work on major...more

Just When We Thought Measure 97 Was Dead—It May Be Back!

by Garvey Schubert Barer on

As I reported previously, Oregon Measure 97 was overwhelmingly defeated by voters in the state’s general election this past November. It certainly appeared that the voters spoke loudly and clearly on November 8, 2016, when...more

South Carolina Court of Appeals, in Olds v. City of Goose Creek, Affirms Circuit Court Order Regarding Definition of Gross Income...

by McNair Law Firm, P.A. on

In Olds v. City of Goose Creek, 2016 S.C. App. LEXIS 147, the South Carolina Court of Appeals provides a thorough discussion of the application of the South Carolina business license tax to a taxpayer’s gross income. The...more

Developing a Plan for Cannabis Industry Banking

Following voter approval of recreational cannabis, the California State Treasurer’s Office reported that by 2020 cannabis sales will increase by an estimated $6.64 billion. By taxing cannabis, California could bring in an...more

Selling Marijuana is still a Federal Crime, but income must be reported

by Sanford Millar on

The prevalence of state laws legalizing the sale of marijuana does nothing to change federal law. Marijuana remains a Schedule 1 drug under the Controlled Substances Act, (21 USC 801, et seq). The act of manufacturing,...more

Withholding Tax Contrary to EU Law: The Brisal Case

On 13 July, the Court of Justice of the European Union (CJEU) released its decision in the Brisal case (C-18/15). The Brisal case has potentially far reaching implications for European Union (EU) businesses that either...more

Brazil: Municipal Service Tax changes will impact dissemination, delivery of advertising and publicity in São Paulo City

by DLA Piper on

This month, the Treasury Department of the City of São Paulo released Normative Ruling SF No. 1/2016 about the Tax on Services (ISS) on the dissemination, provision and insertion of advertising and publicity. ...more

IRS v. Medical Marijuana: IRS 1 Medical Marijuana 0

by Sanford Millar on

The Internal Revenue Code may be the single strongest enforcement weapon in the battle over legal sale and distribution of "medical marijuana". The Opinion of the United States Court of Appeals for the Ninth Circuit, Oliver...more

Marijuana and the Tax Apocalypse

by Sanford Millar on

As Californians evaluate the potential for legalization of Marijuana it is important to consider the current state of conflict between state and federal laws and regulations regarding the production, distribution and sale of...more

Why trustees need to know something about will residue clauses

by Charles E. Rounds, Jr. on

The Anglo-American trust is an invention of the judiciary, specifically the English Court of Chancery. The will, a testamentary instrument, on the other hand, is a creature of statute. The testamentary trust is a product of...more

Equityholder's Strategy for Shifting Tax Burdens to Creditors Upheld by Third Circuit

In re Majestic Star Casino, LLC, F.3d 736 (3rd Cir. 2013), the U.S. Court of Appeals for the Third Circuit broke from other courts by holding that S corporation status (or "qualified subchapter S subsidiary" or "QSub" status)...more

Another Federal Court of Appeals Weighs in on the Applicability of the Six-Year Statute of Limitations Period to an Overstatement...

by McDermott Will & Emery on

The U.S. Court of Appeals for the D.C. Circuit recently reversed two U.S. Tax Court decisions and held that an overstatement of basis constitutes an omission from gross income that is subject to the six-year statute of...more

United States v. UBS AG,

Amended Protocol Between the U.S. and Switzerland (Amending August 2009 Agreement)

by Santiago Cueto on

Switzerland and the US Wednesday 31 March both signed an “amending protocol” to their 19 August 2009 agreement whereby the Swiss promised to issue final decisions on some 4,450 UBS bank clients whose account information was...more

Ninth Circuit Reverses Tax Court on Including Stock Option Costs in Cost-Sharing Agreement: A Tale of Two Regulations

by Morrison & Foerster LLP on

On May 27, in a 2-1 panel decision, the Ninth Circuit Court of Appeals reversed the United States Tax Court in Xilinx, Inc. v. Commissioner and remanded on two specific issues. The Ninth Circuit held that, under Treasury...more

United States v. UBS AG,

U.S. - Switzerland Protocol Amending Treaty for the Avoidance Double Taxation

by Santiago Cueto on

August 2009 agreement whereby Switzerland promised to issue final decisions on some 4,450 UBS bank clients whose account information was requested by US tax authorities. An Amended Protocol was signed on March 31, 2010....more

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